Regulation (EU) 2023/826 specifies that battery-operated products with recharging circuits fall within its scope, as they rely on power from the mains to function as intended. This inclusion affects any rechargeable product listed or described in Annex II of the Regulation. For equipment within the scope, Article 2 defines 'standby mode' and 'off mode' as conditions where the equipment is connected to the mains power source. Annex III points 2(a) and 2(b) also mention connection to the mains power source for “another condition which does not exceed the applicable power consumption requirements”. Consequently, Annex III points 1(a), 1(b), 2(a), and 2(b) apply only when equipment is connected to the mains.
Charging is regarded as one of the primary functions of rechargeable equipment. When equipment is charging, it is performing a main function and is not required to enter standby mode. Additionally, maintenance mode is not subject to any requirements. In that respect, Article 8(d) indicates that a future review will consider the necessity of setting requirements for battery maintenance mode. It follows that if equipment has only charging and maintenance modes when connected to the mains, then the above requirements related to standby and off mode do not apply.
Conversely, Article 2(10) defines 'networked standby' without referring to a mains power connection. Thus, Annex III point 1(c) and 2(c) requirements apply regardless of connection to mains power, and manufacturers must ensure compliance with these provisions.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.